Kentro Group

Kentro Group (“Kentro,” “us,” “we,” or “our”) is committed to protecting Your privacy. Kentro has prepared this Privacy Policy (this “Privacy Policy”) to describe to You or if You represent an entity or other organization, that entity or organization (in either case, “You” or “Your”) our practices regarding the Personal Information that Kentro collects, uses, and shares on behalf of users (“Users”) on http://www.kentrogroup.com (the “Website”).

Kentro reserves the right, at any time, to modify this Privacy Policy.  If revisions are made that change the way we collect, use, or share Personal Information, we will post those changes in this Privacy Policy.  You should review this Privacy Policy periodically so that You keep up to date on our most current policies and practices.  We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.

1. Types of Personal Information. The “Information” we collect about You through the Website includes both “non-personal” and “personal” information.  We may also obtain “sensitive” Personal Information about You through the Website.  For purposes of this Privacy Policy:
   • “Non-Personal Information” refers to information that may not by itself be reasonably associated with, linked to, or used to identify You. For example, non User-specific Information regarding Your use of the Website.
   • “Personal Information” refers to any information collected and stored under Your name. For example, Personal Information may include information such as Your first and last name and, in certain circumstances, Your email address, telephone number, or street address, either alone or in combination with other information.
   • “Sensitive Personal Information” refers to Personal Information regarding more sensitive areas, such as Your government ID and certain other financial information or gender, race/ethnicity, or veteran and disability status.
2. Collection of Personal Information. We may collect Information about You through the Website from a variety of sources, for example:
   • What You Give Us. We collect Information You give us or permit us to access.  Information may include, but is not limited to, Your name, birth date, email and physical address, telephone number, gender, contact lists, social media information and profile, activity and performance information, and when necessary, government ID or other Sensitive Personal Information. In connection with our Investor Portal through our Website, You may provide login credentials, financial information (such as banking information and account number), taxpayer ID number, jurisdiction of tax residence, date of birth, or other investment-related information. We may use any Information You provide to us through the Website in accordance with this Privacy Policy.
   • What We Get From Our Vendors. We may obtain Information about You from the third party vendors that provide services to us.  For example, if we rely on third party services to facilitate registration for the Website, and You register for the Website using that third party, we may receive Information about You from that third party.  We may use any Information that we obtain from our third party vendors in accordance with this Privacy Policy.
   • What We Get From Other Third Parties. We may obtain Information about You from third parties that have obtained or collected Information about You and that have the right to provide that Information to us.  For example, we may contract with third parties that collect or obtain historical information about You or to verify certain Information about You.  We may use any Information about You that we obtain from these third parties in accordance with the terms we establish with those third parties.  We may combine that Information with Information we collect from You under this Privacy Policy.  In that case, we will be required to use that Information in accordance with this Privacy Policy as well.
   • What We Get From Our Affiliates and Subsidiaries. We may obtain Information about You from our affiliates and subsidiaries, including companies that we own or control, that own or control us, or that are under common ownership or control with us.  We may use any Information about You that we obtain from our affiliates or subsidiaries in accordance with the terms under which that Information was collected by that affiliate or subsidiary.  If we combine that Information with Information we collect under this Privacy Policy, then we will use that Information in accordance with this Privacy Policy as well.
   • What We Automatically Collect From You. We may automatically collect the following Information regarding Your interaction with, and use of, our Website:
   • “Cookies” are small bits of information that the Website places on the hard drive of Your computer.  Cookies remember information about Your activities on the Website to make Your visits to the Website more enjoyable and valuable to You by providing a customized experience and recognizing Your preferences when You visit the Website.  If You have chosen to disable cookies on Your browser, some of the functionality of the Website may be lost.  Certain services provided by Kentro require that cookies be enabled in Your browser and cannot be used when You have disabled cookies in Your browser.
   • Flash Cookies (also called Local Shared Objects or “LSOs”). Flash Cookies are data files similar to Cookies, except that they can store more complex data.  Flash Cookies are used to remember settings, preferences and usage, particularly for video, interactive gaming, and other similar services.
   • Web beacons or clear pixels. Web beacons are small graphic images on a web page or in an email that can be used for such things as recording the pages and advertisements that You select, or tracking the performance of email marketing campaigns.
   • Web server logs. Web server logs are records of activity created by the computer that delivers the webpages You request to Your browser.  For example, a web server log may record the search term You entered or the link You clicked to bring You to the webpage.  The web server log also may record information about Your browser, such as Your IP address and the Cookies set on Your browser by the server.
3. USE OF PERSONAL INFORMATION. Kentro’s primary purpose in collecting Personal Information is to facilitate the services that You select on the Website.  Kentro may also use Personal Information for various purposes, including without limitation, to:
   • help diagnose problems with our Website, to administer our Website, and to enhance the Website for optimal User experience;
   • monitor the usage and performance of our Website and to determine aggregate information about our Users;
   • provide maintenance, support, and customer service for the Website;
   • contact Users for information verification purposes;
   • provide products and services to You, such as market commentary and email alerts;
   • manage Your investments;
   • send You promotional materials, newsletters and other communications;
   • create and manage Your account;
   • communicate with You about, and administer Your participation in promotions, surveys and market research;
   • manage Your employment application, assess Your qualifications and manage Your employment with us;
   • operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions);
   • protect against, identify and prevent fraud and other unlawful activity; and
   • comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms of Use located at kentrogroup.com/terms-of-use.
4. Sharing of Personal Information.
   • Kentro Affiliates. We may share Information with our affiliates and subsidiaries, including companies that we own or control, that own or control us, or that are under common ownership or control with us, regardless of whether these companies share our same name.
   • Service Providers. We may transfer Your Information to our service providers to conduct our business.  For example, they may handle identity verification, shipping, data management, email distribution, market research, information analysis, and promotions management. We may also share Your information to administer features of the Website.
   • Advertisers. We may share Information with our third party advertisers.  Our advertisers may use Your Information to display advertisements to You through the Website and advertisements for us on third party web sites.
   • Law Enforcement. We may share Information with law enforcement agencies if we reasonably believe unlawful activities have occurred or the Information may aid in an ongoing investigation.  We may also share Information with law enforcement if we determine, in our sole judgment, that You have violated our agreements or policies or that the release of Your Information may protect the rights, property, interests, or safety of Kentro or any third party.
   • Legal Processes. We may share Information as required by, or permitted by, law, whether in response to subpoenas, court orders, other legal processes, or as we believe is necessary to exercise our legal rights, including defending against legal claims that have been or might be brought against us.
   • Business Transfers. Your Information may be transferred to a third party as a part of our business assets in a sale, merger, reorganization or other transaction involving part or all of Kentro.  If this should happen, we will provide notice to You.
   • Social Networking. The Website may offer You the ability to share Your Information through a social networking site (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables You to share Information about Yourself with other individuals or the public, depending on the settings that You have established with such social networking site.  For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
5. Security. Kentro employs reasonable security measures to protect Information from becoming disclosed to individuals who are not described in this Privacy Policy.  While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to ensure the safety of Your Personal Information.
6. NOTICE TO CALIFORNIA RESIDENTS. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Kentro are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for their direct marketing purposes.  This notice will identify the categories of information shared with third parties and will include a list of the third parties with which it is shared, along with their names and addresses.  If You are a California resident and would like a copy of this notice, please submit a written request to us at the addresses listed below.
7. Other Websites. This Privacy Policy does not apply to web sites or applications offered by other organizations or individuals that may be displayed as content in a search on the Website.  Kentro encourages You to read the Privacy Policy of any third party web site or applications before transmitting Personal Information.
8. ADDITIONAL TERMS.
   • If Your Personal Information is incorrect, You may correct the Personal Information by sending a written request for correction to Kentro’s address listed below. Your request must include: (1) all of the incorrect Personal Information that You wish to change, (2) the corrected Personal Information, and (3) Your signature authorizing such changes. Kentro will then correct the Personal Information in our database and send a written confirmation to You.
   • Some web browsers and devices permit You to broadcast a preference that You not be “tracked” online. At this time, Kentro does not modify Your experience based upon whether such a signal is broadcast.
   • Your use of our Website, and any disputes arising from them, is subject to this Privacy Policy as well as our Terms of Use. Please visit our Terms of Use which explains other terms governing the use of our Platform
9. Communications. If You have any additional questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:

Kentro Group

Attn: Legal & Compliance

1509 York Street

Suite # 201

Denver, CO 80206

Legal@kentrogroup.com

If Kentro needs, or is required, to contact You concerning any event that involves information about You, we may do so by email, telephone, or mail.
Effective as of May 15, 2017